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305 results for “reassessment u/s 147”+ Section 69Cclear

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Key Topics

Section 147170Section 148162Section 68151Section 69C81Addition to Income80Reassessment47Reopening of Assessment34Section 143(3)33Section 143(2)

SHYAM PRODUCTS P.LTD,NEW DELHI vs. ITO, WARD-23(3), NEW DELHI

In the result, appeal of the assessee is partly allowed as indicated above

ITA 4908/DEL/2018[2007-08]Status: DisposedITAT Delhi31 Jan 2023AY 2007-08

Bench: Shri Challa Nagendra Prasad, S.M.C.

For Appellant: Shri Suresh Kumar GuptaFor Respondent: Sr. D. R
Section 147Section 148Section 271Section 68Section 69C

reassessment proceedings ignoring the fact that initiation of the proceedings u/s 148 and the consequent order u/s 147 are bad in law as: a. The initiation of proceedings u/s 148 are contrary to provisions of law. b. The mandatory procedure laid down in the Act has not been followed. c. The information has been collected behind the back

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Section 26327
Section 15124
Natural Justice23

OPTIMIST ELECTRONICS P.LTD,NEW DELHI vs. ITO, WARD-19(2), NEW DELHI

In the result, appeal of the assessee is partly allowed as indicated above

ITA 4907/DEL/2018[2008-09]Status: DisposedITAT Delhi31 Jan 2023AY 2008-09

Bench: Shri Challa Nagendra Prasad, S.M.C.

For Appellant: Shri Suresh Kumar GuptaFor Respondent: Sr. D. R
Section 147Section 148Section 271Section 68Section 69C

reassessment proceedings ignoring the fact that initiation of the proceedings u/s 148 and the consequent order u/s 147 are bad in law as: a. The initiation of proceedings u/s 148 are contrary to provisions of law. b. The mandatory procedure laid down in the Act has not been followed. c. The information has been collected behind the back

WARM FORGINGS P.LTD,NEW DELHI vs. DCIT, CIRCLE-27(1), NEW DELHI

In the result, appeal of the assessee is allowed as indicated

ITA 1148/DEL/2019[2010-11]Status: DisposedITAT Delhi03 Apr 2024AY 2010-11

Bench: Shri Challa Nagendra Prasad & Dr. B.R.R. Kumarआ.अ.सं/.I.T.A No.1148/Del/2019 िनधा"रणवष"/Assessment Year: 2010-11 बनाम Warm Forgings P. Ltd., Dcit Plot No.117 & 118, A-3, Vs. Circle 27(1), Sector-11, Rohini, New Delhi. New Delhi. Pan No.Aabcc7684C अपीलाथ" Appellant ""यथ"/Respondent

Section 143(3)Section 147Section 148Section 153CSection 68Section 69C

147 of the Act by the AO without independent application of mind to the facts of the case and without verification of the material placed on his record during the original assessment proceedings completed u/s 143(3) of the Act. Thus the reopening of the assessment is bad in law and the assessment order so made should be cancelled

MAHESHWARI ROLLER FLOUR MILLS PVT LTD,NEW DELHI vs. ITO WARD - 16(1), NEW DELHI

In the result, appeal of the Assessee allowed

ITA 4257/DEL/2019[2009-10]Status: DisposedITAT Delhi15 Dec 2020AY 2009-10

Bench: Shri Bhavnesh Saini & Shri O.P. Kant

For Appellant: Shri Raj Kumar, C.AFor Respondent: Shri Prakash Duby, Sr. DR
Section 143(1)Section 147Section 148Section 150(1)Section 150(2)Section 2Section 68Section 69C

69C of the I.T. Act, 1961 on account of unexplained expenditure. 2. We have heard the Learned Representatives of both the parties through video conferencing and perused the material on record. 3. Briefly the facts of the case are that assessee is a company which was incorporated on 20.06.1988 under the Company Act, 1956. The assessee-company filed its return

PASSION REALTECH PVT LTD,GURGAON vs. ;ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeals in ITA

ITA 1269/DEL/2025[2012-13]Status: DisposedITAT Delhi26 Nov 2025AY 2012-13

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 143(2)Section 147Section 148Section 151Section 153C

69C is wholly unjustified. 9.5. The Hon’ble Gujarat High Court in the cases of CIT Vs. Ayachi Chandrasekhar Narsangji, 42 Taxmann.com 251 (Guj) and CIT Vs. Mahavir Crimpers, 95 Taxman.com 323 (Guj) have held that when the Department has accepted the factum of repayment, the additions under Section 68 is not sustainable in law. Similar view has been expressed

PASSION REALTECH PVT LTD,GURGAON vs. ACIT, CENTRAL CIRCLE-2, FARIDABAD

In the result, Appeals in ITA

ITA 1268/DEL/2025[2011-12]Status: DisposedITAT Delhi26 Nov 2025AY 2011-12

Bench: Shri S. Rifaur Rahman & Shri Yogesh Kumar U.S.

Section 143(2)Section 147Section 148Section 151Section 153C

69C is wholly unjustified. 9.5. The Hon’ble Gujarat High Court in the cases of CIT Vs. Ayachi Chandrasekhar Narsangji, 42 Taxmann.com 251 (Guj) and CIT Vs. Mahavir Crimpers, 95 Taxman.com 323 (Guj) have held that when the Department has accepted the factum of repayment, the additions under Section 68 is not sustainable in law. Similar view has been expressed

ANIL KUMAR JAIN,NEW DELHI vs. DY. COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-26, JHANDEWALAN, NEW DELHI

In the result, the appeal of the assessee is allowed

ITA 475/DEL/2025[2013-14]Status: DisposedITAT Delhi16 Jan 2026AY 2013-14

Bench: SHRI YOGESH KUMAR U.S. (Judicial Member), SHRI MANISH AGARWAL (Accountant Member)

Section 143(1)Section 143(3)Section 147Section 148Section 151

reassessment u/s 148 qua genuineness of unsecured loan as well as purchases disclosed, considered and accepted during the original assessment under Section 143(3) of the Income Tax Act, 1961 for AY 2013-14 2. On the facts and circumstances of the case, the impugned order dated 10th December 2024 passed by the CIT(A) as well as order dated

SKY BLUE INFOTECH PVT LTD,NEW DELHI vs. ITO WARD - 23(4), NEW DELHI

In the result, appeal of the assessee is partly allowed as

ITA 438/DEL/2020[2010-11]Status: DisposedITAT Delhi13 Dec 2024AY 2010-11

Bench: Shri Challa Nagendra Prasadआ.अ.सं/.I.T.A No.438/Del/2020 िनधा"रणवष"/Assessment Year: 2010-11 बनाम Sky Blue Infotech Pvt. Ltd. Income Tax Officer 206, Hans Bhawan, 1, Vs. Ward-23(4), Bahadurshah Zafar Marg, Room No.246, C.R. Bldg., New Delhi. I.P. Estate, New Delhi. Pan No. Aalcs1584K अपीलाथ" Appellant ""यथ"/Respondent

Section 147Section 148Section 151Section 271(1)(c)Section 68Section 69C

69C as alleged commission paid for obtaining accommodation entries; I.T.A. No. 438/Del/2020 3. The Ld.CIT(A) has erred on facts and in law in upholding the impugned order of the Ld. Assessing Officer which is contrary to law, passed without application of mind and without complying with the procedure and rules, is against equity and justice and facts

SHARK PACKAGING (INDIA) PRIVATE LIMITED,DELHI vs. ITO,WARD-23(1), NEW DELHI

In the result, the appeal of the assessee for AY 2012-13 is partly allowed only on ground no

ITA 2163/DEL/2022[2008-09]Status: DisposedITAT Delhi17 Oct 2023AY 2008-09

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Mayank Patawari, AdvFor Respondent: Shri Anuj Garg, Addl. CIT
Section 147Section 148Section 253Section 46ASection 68Section 69C

69C of the Income tax Act, 1961 on account commission @ 1.8% has been eared on providing accommodation entries. 3. We have heard arguments on the application of assessee dated 13.06.2023 seeking admission of additional ground no. 3 u/s. 253 of the Act r.w.r 11 of Income Tax (Appellate Tribunal) Rules 1963. The ld. counsel submits that the proposed additional ground

SHARK PACKAGING (INDIA) PVT LTD,NEW DELHI vs. ITO WARD - 23(1), NEW DELHI

In the result, the appeal of the assessee for AY 2012-13 is partly allowed only on ground no

ITA 8310/DEL/2019[2012-13]Status: DisposedITAT Delhi17 Oct 2023AY 2012-13

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Mayank Patawari, AdvFor Respondent: Shri Anuj Garg, Addl. CIT
Section 147Section 148Section 253Section 46ASection 68Section 69C

69C of the Income tax Act, 1961 on account commission @ 1.8% has been eared on providing accommodation entries. 3. We have heard arguments on the application of assessee dated 13.06.2023 seeking admission of additional ground no. 3 u/s. 253 of the Act r.w.r 11 of Income Tax (Appellate Tribunal) Rules 1963. The ld. counsel submits that the proposed additional ground

SHARK PACKAGING (INDIA) PVT LTD,NEW DELHI vs. ITO WARD - 23(1), NEW DELHI

In the result, the appeal of the assessee for AY 2012-13 is partly allowed only on ground no

ITA 8309/DEL/2019[2011-12]Status: DisposedITAT Delhi17 Oct 2023AY 2011-12

Bench: Shri Chandra Mohan Garg & Shri Pradip Kumar Kedia

For Appellant: Shri Mayank Patawari, AdvFor Respondent: Shri Anuj Garg, Addl. CIT
Section 147Section 148Section 253Section 46ASection 68Section 69C

69C of the Income tax Act, 1961 on account commission @ 1.8% has been eared on providing accommodation entries. 3. We have heard arguments on the application of assessee dated 13.06.2023 seeking admission of additional ground no. 3 u/s. 253 of the Act r.w.r 11 of Income Tax (Appellate Tribunal) Rules 1963. The ld. counsel submits that the proposed additional ground

ADDL.CIT, SPECIAL RANGE-18, NEW DELHI vs. JAGANANTH HEMCHAND JAIN, NEW DELHI

In the result, the appeal of the Revenue as well as Cross Objection of the assessee is dismissed

ITA 7754/DEL/2018[2010-11]Status: DisposedITAT Delhi29 Feb 2024AY 2010-11

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Us

Section 143(3)Section 145(3)Section 147Section 148Section 148(2)Section 69C

reassessment proceedings and grants primacy to Section 153C of the Act. As noted earlier, exercise of power under S. 153C is governed without any stringent fetters of holding 'reason to believe' contemplated under S. 147. Therefore, while exercise of overriding power under S. 153C will render S. 147 otiose, the converse case of clipping the powers available under S. 147

ADDL.CIT, SPECIAL RANGE-18, NEW DELHI vs. JAGANANTH HEMCHAND JAIN, NEW DELHI

In the result, the appeal of the Revenue as well as Cross Objection of the assessee is dismissed

ITA 7755/DEL/2018[2011-12]Status: DisposedITAT Delhi29 Feb 2024AY 2011-12

Bench: Shri Pradip Kumar Kedia & Shri Yogesh Kumar Us

Section 143(3)Section 145(3)Section 147Section 148Section 148(2)Section 69C

reassessment proceedings and grants primacy to Section 153C of the Act. As noted earlier, exercise of power under S. 153C is governed without any stringent fetters of holding 'reason to believe' contemplated under S. 147. Therefore, while exercise of overriding power under S. 153C will render S. 147 otiose, the converse case of clipping the powers available under S. 147

SUSHIL BANSAL,NEW DELHI vs. ACIT, CIRCLE- 57(1), NEW DELHI

In the result, the appeal is dismissed

ITA 4441/DEL/2017[2013-14]Status: DisposedITAT Delhi23 Oct 2018AY 2013-14

Bench: : Shri Amit Shukla & Shri L.P. Sahuassessment Year: 2013-14

Section 132Section 147Section 148Section 151Section 69C

147 read with Section 148 2 are bad in law as the conditions and procedure prescribed under the statute have not been satisfied and complied with. 3.(i) On the facts and circumstances of the case, Id. CIT(A) has erred both on facts and in law in rejecting the contention of the assessee that the reassessment proceedings initiated

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

ITA 2935/DEL/2023[2014-15]Status: DisposedITAT Delhi30 Aug 2024AY 2014-15

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

ITA 2938/DEL/2023[2017-18]Status: DisposedITAT Delhi30 Aug 2024AY 2017-18

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

ITA 2936/DEL/2023[2015-16]Status: DisposedITAT Delhi30 Aug 2024AY 2015-16

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets

ANIL CHAUDHARY,NEW DELHI vs. ACIT CENTRAL CIRCLE-17, NEW DELHI

In the result, appeals filed by the assessee are allowed

ITA 2937/DEL/2023[2016-17]Status: DisposedITAT Delhi30 Aug 2024AY 2016-17

Bench: Shri S.Rifaur Rahman & Shri Anubhav Sharma

For Appellant: Shri Gautam Jain, AdvocateFor Respondent: Ms. Amisha Gupt, CIT DR
Section 127Section 143(2)Section 153ASection 153CSection 153DSection 69C

147, section 148, section 149, section 151 and section 153, where the Assessing Officer is satisfied that any money, bullion, jewellery or other valuable article or thing or books of account or documents seized or requisitioned belongs or belong to a person, other than the person referred to in section 153A, then the books of account or documents or assets

PRAKHAR DALMIA,NEW DELHI vs. ACIT CIRCLE-34(1), NEW DELHI

In the result, appeal filed by the assessee is partly allowed

ITA 3325/DEL/2019[2014-15]Status: DisposedITAT Delhi10 May 2024AY 2014-15

Bench: Us & Prayed That Additional

Section 10(38)Section 127Section 132Section 143(2)Section 143(3)Section 153ASection 68Section 69C

69C of the Act, based on conjecture and surmises and without any evidence on record to substantiate the same.” 3. Further, assessee has filed a petition for admission of additional grounds of appeal before us and prayed that additional grounds may be admitted for adjudication and reliance was placed on the decision of Hon’ble Supreme Court in the case

SANDEEP KUMAR,NEW DELHI vs. ITO - WARD 1, PANIPAT, PANIPAT

In the result, appeal of the assessee is allowed

ITA 4348/DEL/2025[2018-19]Status: DisposedITAT Delhi28 Nov 2025AY 2018-19

Bench: Shri Mahavir Singh & Shri Manish Agarwal[Assessment Year : 2018-19] Sandeep Kumar, Vs Ito C/O-B-50, Lgf, South Ward-1 Extension Part-Ii, Panipat New Delhi -110049 Pan-Aueps5626A Appellant Respondent Appellant By Shri Shantanu Jain, Adv. Ms. Jahnavi Khanna, Adv. Shri Gurjeet Singh, Ca Respondent By Shri Khitesh Gupta, Sr.Dr Date Of Hearing 26.11.2025 Date Of Pronouncement 28.11.2025 Order

Section 147Section 148Section 250Section 263Section 69C

147 r.w.s. 144B of the Act dated 24.03.2023 which is sought to be revised u/s 263 of the Act itself was invalid on various grounds and thus proceedings initiated u/s 263 of the Act against the invalid reassessment order is clearly bad in law. 6. That the appellant craves the leave to add, amend, modify, DLEETE any of the grounds